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A “qualifying investor” in a closed FGR is any investor that, at the time of any payment in respect of which relief is requested, is an investor that is: considered, under the terms of a tax treaty entered into between Canada and another jurisdiction, resident in that other jurisdiction and eligible to receive any of the benefits provided for in that tax treaty in respect of the payment in its own right; Note Entities or arrangements that are considered to be wholly or partly fiscally transparent in Canada or in that other jurisdiction, for example, partnerships, certain limited liability companies or equivalent entities, co ownership funds, are not qualifying investors. another closed FGR in which each investor is a resident of the Netherlands under the Canada-Netherlands Income Tax Convention; a Canadian registered pension plan. ...

For example, when the BTS applicant is under contract to a major studio to perform services on a number of separate projects, the projects are considered to be related. Repetitive services Services are considered repetitive when the BTS applicant routinely provides services in Canada in the same geographic location. ...

Effect of APA rollback on the transfer pricing penalty Once an APA is in force, the results for the covered transactions occurring within the period specified in the APA will be considered to have satisfied section 247 of the Act. ... A taxpayer is considered to have requested an APA rollback once a pre-filing meeting has taken place between the taxpayer and the Competent Authority Services Division (CASD) officials regarding a potential APA rollback. ...

For the purposes of calculating the maximum number of meals allowed, a day is considered to be a 24-hour period that begins at the departure time. ... The costs of showers are also considered to be deductible as part of lodging expenses for transportation employees who may have slept in the cab of their trucks rather than at hotels. ...

In such a situation the proceeds will be on account of capital and if there is a reasonable expectation at the time of disposition of the property that the conditions will be met, then the disposition is treated in the ordinary manner, and the original maximum amount is considered to be the sale price of the property. ... IT-426, "Shares Sold Subject to an Earnout Agreement", will be considered appropriate only in the circumstances referred to therein. ...

A genuine loan to a trust would not by itself be considered to result in property being "held" by the trust under one or more of these conditions (i.e., would not by itself result in the application of subsection 75(2)), if the loan is outside and independent of the terms of the trust. For a discussion on when a loan can be considered genuine, see the current version of IT-258, Transfer of Property to a Spouse and IT-260, Transfer of Property to a Minor. ...

Any of the above would be considered an option on a share where it contains an irrevocable offer in respect of a specified period of time to acquire a share. 4. ... For example, if a non-resident owns 15% of the shares of a public corporation and has an interest in or option on another 15% of the same class of shares, the 25% requirement is met and any gain on the disposition of one or more of the corporation's shares, or on the disposition of the interest or option, will be considered to be a gain on the disposition of taxable Canadian property. ...

A municipality will be considered to own an organization if: it owns 90 per cent or more of the shares or capital of the organization; or it holds title to the assets of the organization or controls their disposition, such that in the event of wind-up or liquidation, these assets are vested in the municipality. A municipality will be considered to control an organization if: it appoints more than 50 per cent of the members of the governing body of the organization (e.g. directors, governors, commissioners); and the organization must submit to the municipality its operating and, where applicable, capital budget for review and approval. ...

Just as a "like event" that is combined with a chance to win a prize or a draw is not considered a "like event", similarly a "like event" that is combined with an auction is also not considered a "like event". ...

Rationale Company A is considered to be the supplier of the book to Company C because Company A buys the book from Company B and resells the book, not as agent, but as principal, to the recipient, Company C. ... Rationale Company X is considered to be the supplier of the subscription to the magazine to Company Y because Company X sells the subscription to the magazine directly to the recipient, Company Y. ...